BHURE LAL,KHANDWA vs. ITO-2, KHANDWA

ITA 835/IND/2025Status: DisposedITAT Indore30 June 2026AY 2017-1817 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that the change in currency note denominations between withdrawal and deposit does not invalidate the source of funds, which were explained as retirement benefits. The addition made under Section 69A was therefore not sustainable.

What were the facts?

The assessee, a retired government servant, deposited a significant amount of cash into his bank account during the demonetization period. The Assessing Officer (AO) added Rs. 14,00,000/- to the assessee's income as unexplained money, citing a mismatch in currency note denominations between withdrawal and deposit.

What were the issues?

Whether the addition of unexplained money under Section 69A is justified solely based on a mismatch in currency note denominations when the source of funds is otherwise explained and supported by evidence.

Which sections of the Income-tax Act were involved?

Section 69A,Section 115BBE

AI-generated summary — verify with the full judgment below

Income Tax Appellate Tribunal, INDORE BENCH, INDORE

Before: DR. ARJUN LAL SAINI & SHRI PARESH M. JOSHI

For Appellant: Shri Vijay Bansal, AR
For Respondent: Shri Ashish Porwal, Sr. DR
Hearing: 08.06.2026Pronounced: 30.06.2026

Per Paresh M. Joshi, JM:

This is an Appeal filed by the Assessee under section 253 of the income tax Act 1961,[ herein after referred to as the Act

for the sake of brevity] before this tribunal as & by way of a second Appeal. The Assessee is aggrieved by the order

bearingNumber:-ITBA/NFAC/S/250/2025-

26/1078775074(1) dated 22.07.2025 passed by the Ld.

Bhure Lal CIT(A), which is hereinafter referred as the “impugned

order”. The relevant assessment is 2017-18 and the corresponding previous year period is from 01.04.2016 to 31.03.2017. 2. Factual Matrix

2.

1 That as & by way of an assessment order made u/s 144

of the Act, the total income of the assessee was computed &

assessed at Rs.18,94,12

The order continues below.

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